This "go-to," "must-have," "must-read" book is a cornerstone of trial preparation. Published by Trial Guides, this book covers everything from the purpose and strategy of depositions through to specific questions and techniques that can be used in any deposition. The most important takeaway from this book is that every deposition must have a specific goal—the authors identify common goals and strategies to achieve them.

Miller and Scoptur explain, "If you haven't won the case in depositions, it is unlikely that it will happen in the courtroom."

In Advanced Depositions, Miller and Scoptur teach critical skills, like:

• "Restating and Summarizing"
• "Boxing In"
• "Establishing Rules" and
• "Dealing with Evasive Witnesses."

The book begins with a chapter dedicated to "Understanding Juror Attitudes and Beliefs," emphasizing from the outset that a deposition is not merely a discovery tool. Rather, every deposition must be designed around its potential use at trial. Therefore, when done correctly, a deposition provides key admissions for trial, quotes for impeachment, and leverage for settlement.

Advanced Depositions dedicates several detailed chapters to depositions of expert witnesses. There, the authors clearly set out thoughtful lines of questioning akin to Friedman and Malone’s, “Rules of the Road,” and also offer high level strategies. For example, the authors explain how to develop an expert deposition around the Daubert framework for exclusion. This way, critical research is performed at the outset, testimony is developed corresponding to case law, and a motion to strike or exclude follows naturally.

Among its highlights, Advanced Depositions is filled with useful examples, providing ideas for questions to ask, as well as helpful transcript excerpts from real cases. Rather than a prescriptive list of tips or rules, it provides an insightful guide for every lawyer to tailor to her own practice.

This is a book to read thoroughly, then keep for frequent consultation. It is available from TrialGuides.com at the link below:

https://www.trialguides.com/products/advanced-depositions-strategy-and-practice